248 Jared Ln - Staff Report and Exhibits 15 - 17
PREPARED BY: SEAN MULLIN, AICP
Associate Planner
Reviewed by: Community Development Director
110 E. Main Street Los Gatos, CA 95030 ● 408-354-6874
www.losgatosca.gov
TOWN OF LOS GATOS
PLANNING COMMISSION
REPORT
MEETING DATE: 09/26/2018 ITEM NO: 2
DATE: SEPTEMBER 17, 2018 TO: PLANNING COMMISSION FROM: JOEL PAULSON, COMMUNITY DEVELOPMENT DIRECTOR SUBJECT: ARCHITECTURE AND SITE APPLICATION S-16-054. PROJECT LOCATION:
248 JARED LANE. PROPERTY OWNER/APPLICANT: SAM PAN. REQUESTING APPROVAL FOR CONSTRUCTION OF A NEW SINGLE-FAMILY RESIDENCE AND REMOVAL OF LARGE PROTECTED TREES ON VACANT PROPERTY ZONED HR-1. APN 532-34-071.
BACKGROUND:
The Planning Commission considered this application on April 11, 2018 and continued the
matter to May 23, 2018 to allow the applicant to address the following:
• Provide more information on cut, fill, and grading as it relates to the placement of the
driveway;
• Continue outreach to the neighbors;
• Consider building within the Least Restrictive Development Area (LRDA) or reduce the
encroachments outside of the LRDA; and
• Consider reducing massing.
The revised application was not ready for the May 23, 2018 Planning Commission meeting,
which was subsequently cancelled due to lack of items. Written notice for this meeting was
sent out to all property owners and occupants with 300 feet of the project site.
DISCUSSION:
In response to the comments received from the public and the Planning Commission at the
April 11, 2018 meeting, the applicant provided additional information and submitted revised
development plans to address concerns regarding maximum cut and fill depths related to the
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placement of the driveway (Exhibit 17). The changes reflected in the revised plans are provided
below:
Maximum cut and fill depths and grading:
The applicant revised the driveway slopes in order to reduce maximum cut and fill depths.
The applicant increased the initial slope of the driveway from Jared Lane which allowed a
reduction in slope at the middle section of the driveway. As a result, the maximum slope of
the driveway has been reduced from 19.53 percent to 15.00 percent. This revision
eliminates the need for an exception to maximum driveway slope. Additionally, by reducing
the driveway slope, the maximum height of the retaining walls has been reduced from 14.2
feet to 8.3 feet; and the maximum fill depth has been reduced from 16 feet to 12 feet.
While these revisions do not bring the maximum cut and fill depths within the limitations of
the Hillside Development Standards and Guidelines (HDS&G), they do reduce the impact on
the site and reduce the extent of the exceptions being requested for the driveway. A
comparison of the previously proposed project and the current proposal is provided below.
Maximum Cut and Fill Depths and Retaining Wall Heights – HDS&G
April 11, 2018
Proposal
Current
Proposal
Difference Maximum
Allowed
Maximum
Cut Fill Cut Fill Cut Fill Cut Fill
House Footprint
Depth (feet) 24* 0 24* 0 0 0 8* 3
Volume (yd3) 2,891 332 2,891 332 0 0 N/A N/A
Driveway
Depth (feet) 15* 16 15* 12 0 -4 4* 3
Volume (yd3) 110 1,118 397 853 +297 -265 N/A N/A
Site Work
Depth (feet) 7* 0 7* 0 0 0 4* 7
Volume (yd3) 405 0 405 0 0 0 N/A N/A
Maximum Retaining
Wall Height (feet) 14.2 8.3 -5.9 5
* – Excludes below-grade square footage
Bold – requires exception to the HDS&G
Neighborhood outreach:
The applicant provided an updated record of their neighbor outreach efforts (Exhibit 16,
page N-1). This record includes efforts following the April 11, 2018 Planning Commission
meeting.
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Development outside of the LRDA:
Standard II.C.1 of the HDS&G (page 17) indicates that buildings shall be located within the
LRDA. For properties outside of Sub-area 1 as provided in the Hillside Specific Plan, the
HDS&G allows for exceptions from the standards, which can be granted after carefully
considering the constraints of the site (page 67). Any deviation from the standards shall
include the rationale and evidence to support the deviation. The burden of proof is on the
applicant to show that there are compelling reasons for granting the requested deviation.
The exception process contained in the HDS&G does not prescribe a limitation on the
extent of the deviation allowed under an exception; rather, the document requires
examination by the deciding body of the specific site constraints, the rationale for the
requested exception, and the evidence provided by the applicant.
The applicant has not revised the design or siting of the proposed residence and the
encroachment of the residence outside of the LRDA remains consistent with that presented
on April 11, 2018. As requested by the Commission at the April 11, 2018 meeting, the
applicant has provided a comparison of the current proposal and the previously approved
2011 project (Exhibit 16, pages P-0 through P-3). The table below summarizes this
comparison.
Comparison of Area Outside of LRDA: 2011 vs. 2018 projects
House Amenities* Total
2011 908 sf
(24%)
1,973 sf
(52 %)
2,881 sf
(76%)
2018 346 sf
(11%)
886 sf
(27%)
1,232 sf
(38%)
* Amenities refers to terraces, decks, porches, and stairs.
Massing:
The applicant has not revised the massing of the proposed residence from what was
presented on April 11, 2018. The applicant has provided a comparison of the massing of the
current proposal to that of the previously approved 2011 project (Exhibit 16, pages P-4
through P-7). Additionally, the applicant has prepared a scale model which will be available
to aid in the review of massing and visibility at the September 26, 2018 meeting (Exhibit 16,
page M-1).
PUBLIC COMMENTS:
No public comments have been received as of the writing of this report.
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CONCLUSION AND RECOMMENDATION:
A. Conclusion
The applicant has responded to the Planning Commission’s direction with revised plans and
additional information. The Planning Commission should determine whether the project
revisions and additional information adequately addresses the direction provided at the April
11, 2018 meeting.
B. Recommendation
If the Planning Commission determines that the revised project and additional information
adequately addresses the direction provided at the April 11, 2018 meeting and finds merit
with the proposed project, it can approve the application by taking the following actions:
1. An Initial Study, Mitigated Negative Declaration (MND), and Mitigation Monitoring and
Reporting Program (MMRP) were adopted in 2011 for a similar single-family
development application. An Initial Study for the current application concluded that the
project is within the scope of the previous project. The Initial Study found that the
current project would not result in any new environmental impacts or result in a
substantial increase to a previously identified significant environmental impact. All
previously identified significant environmental impacts would continue to be mitigated
through implementation of the measures included in the adopted MMRP from 2011. An
Addendum has been prepared for the proposed application under CEQA Guidelines
Sections 15162 and 15164 (previously received under separate cover). The decision-
making body shall consider the Addendum with the adopted Mitigated Negative
Declaration prior to deciding on the project. No additional CEQA findings are required.
2. Make the finding that due to the constraints of the site, exceptions to the Least
Restrictive Development Area, maximum retaining wall heights and lengths, and
maximum cut and fill depths are appropriate, and the project is otherwise in compliance
with the applicable sections of the Hillside Development Standards and Guidelines
(Exhibit 15);
3. Make the finding that the project complies with the Hillside Specific Plan (Exhibit 15);
4. Make the required considerations as required by Section 29.20.150 of the Town Code
for granting approval of an Architecture and Site application (Exhibit 15); and
5. Approve Architecture and Site Application S-16-054 with the conditions contained in
Exhibit 3 and the development plans in Exhibit 17.
ALTERNATIVES:
Alternatively, the Commission can:
1. Approve the application with additional and/or modified conditions;
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2. Continue the matter to a date certain with specific direction; or
3. Deny the application.
EXHIBITS:
Previously received under separate cover:
Addendum to previously adopted Mitigated Negative Declaration
Previously received with the April 11, 2018 Staff Report:
1. Location Map
2. Required Findings and Considerations (one page)
3. Recommended Conditions of Approval (16 pages)
4. Site Photos (five pages)
5. Color and Materials Sheet, received August 4, 2017 (one page)
6. Letter of Justification, received February 1, 2018 (15 pages)
7. Consulting Architect Report, dated May 15, 2017 (six pages)
8. Applicant’s Arborist Report by Ian Geddes, dated August 18, 2016 (29 pages)
9. Consulting Arborist’s Peer Review Report by Walter Levison, dated May 5, 2017 (20 pages)
10. Applicant’s Arborist Addendum by Ian Geddes, dated October 25, 2017 (seven pages)
11. Applicant’s Arborist Addendum by Ian Geddes, dated December 1, 2017 (nine pages)
12. Consulting Arborist’s Peer Review Report by Walter Levison, dated December 1, 2017
(19 pages)
13. Public comments received by 11:00 a.m., Friday, April 6, 2018
14. Development Plans, received March 1, 2018 (33 sheets)
Received with this Staff Report:
15. Revised Required Findings and Considerations (one page)
16. Additional Letter of Justification, received September 4, 2018 (19 pages)
17. Development Plans, received August 29, 2018 (34 sheets)
Distribution:
Sam Pan, 1901 Nobili Avenue, Santa Clara, CA 95051
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N:\DEV\FINDINGS\2018\Jared 248 - PC Findings 09-26-18.docx
PLANNING COMMISSION – September 26, 2018
REQUIRED FINDINGS & CONSIDERATIONS FOR:
248 Jared Lane
Architecture and Site Application S-16-054
Requesting approval for construction of a new single-family residence and removal
of large protected trees on vacant property zoned HR-1. APN 532-34-071.
PROPERTY OWNER/APPLICANT: Sam Pan
FINDINGS
Required Finding for CEQA:
■ An Initial Study, Mitigated Negative Declaration (MND), and Mitigation Monitoring and
Reporting Program (MMRP) were adopted in 2011 for a similar single-family
development application. An Initial Study for the current application concluded that the
project is within the scope of the previous project. The Initial Study found that the
current project would not result in any new environmental impacts or result in a
substantial increase to a previously identified significant environmental impact. All
previously identified significant environmental impacts would continue to be mitigated
through implementation of the measures included in the adopted MMRP from 2011. An
Addendum has been prepared for the proposed application under CEQA Guidelines
Sections 15162 and 15164. The decision-making body shall consider the Addendum
with the adopted Mitigated Negative Declaration prior to deciding on the project. No
additional CEQA findings are required.
Required Compliance with Hillside Development Standards and Guidelines (HDS&G):
■ The project is in compliance with the Hillside Development Standards and Guidelines
with exceptions to the Least Restrictive Development Area, maximum retaining wall
heights and lengths, and maximum cut and fill depths. The vacant site lot is 1.65 acres
(71,814.6 square feet) with an average slope of 35.8 percent, extensive tree cover, and
an ephemeral drainage along the southwest portion of the property. Due to these
constraints, the 71,814.6-square foot property includes a limited LRDA of 6,056 square
feet, which is located in the northern portion of the property at the highest elevations.
The applicant has sited the majority of the proposed residence within the LRDA (62.8
percent). The retaining walls adjacent to the driveway are required to construct the
driveway, which would provide safe ingress and egress to the site. The applicant has
provided compelling reasons and evidence to support the granting of exceptions to the
Hillside Development Standards and Guidelines.
EXHIBIT 15
N:\DEV\FINDINGS\2018\Jared 248 - PC Findings 09-26-18.docx
Compliance with Hillside Specific Plan
■ The project is in compliance with the Hillside Specific Plan in that it is a single-family
residence being developed on an existing parcel. The proposed development is
consistent with the development criteria included in the Specific Plan.
CONSIDERATIONS
Considerations in review of Architecture & Site applications:
■ As required by Section 29.20.150 of the Town Code, the considerations in review of an
Architecture and Site application were all made in reviewing this project.
Justification Page 1
September 4th, 2018
Design Justification
The A/E design team has collaboratively & exhaustively prepared a set of up-to-date documents
after the 4/11/2018 Planning Commission Meeting.
This round submittal consists of the modified engineering work of drive way slope and
associated retaining wall appearance including the inclination of protected & un-protected oak
trees plus architectural design documents having unchanged, in other words, the latter design
basically is the same as those presented during the 4/11 meeting, however, justifications of
that design described hereinafter providing reasonable comparison of two designs one in 2011
and one in 2018. Additionally, it will be more convincing as a scaled site/building model to be
presented in the forthcoming meeting to transform the overall design of architectural &
engineering in a very harmonious hillside design it would easily blend with the nature
environment and maintain the character of an open, wooded, and rural site.
The prior design is recognized by the Town Planning Commission in 2011, and the current
design is pending and really deserved an apple-to-apple comparison with that previously
approved so that pros and cons of design provided within two different periods can be assessed
for a reasonable conclusion.
The following items are several proper approaches that Commissioners can focus on for the A/E
design clarifications and justifications prior to decision making.
1) Grading (cut/fill) Study
2)LRDA Analysis
3) Massing Review
4) Condition of On-site Trees
5) Outreach to Neighbors
6) Other considerations
The explanations with regards to these items listed above can be found in the pages after
bulletins;
•Grading: C-1 & C-2
Mainly it focuses on the driveway slope 15% in lieu of 20% and earth cut & fills
quantities at driveway & house
•LRDA & related: Two pages, P-0 & P-00
EXHIBIT 16
Justification Page 2
Contains LRDA analysis & a table shows pertinent numbers in 2011 & 2018
•Massing: Three-page floor plans (P-1, P-2, & P-3)
Contain size of plans & others provided in 2011 & 2018
Four-page elevation plans (P-4, P-5, P-6, & P-7)
Contain above-grade mass matching comparison provided in 2011 & 2018
•Trees: T-1
Quantity of protected trees retained & removed including method for enhanced privacy
•Neighbors: N-1 & N-2
Outreach to several adjacent neighbors, total seven
Page N-1 - logged dates owner personally paid visits to neighbors who expressed their
opinions
Page N-2 - shows a vicinity map of neighbors who have attended April 11th meeting
•Other Considerations: O-1
Facts commissioners could take into consideration of their merits for the success of the
project completion beyond all explained after each bulletin above
The lot has an average slope of approximately 36%. The site has two areas that would qualify as
the Least Restrictive Development Area (LRDA) as defined by the Town’s Hillside Development
Standards and Guidelines (Standards and Guidelines). One of the LRDA is located within the
creek bed, which prohibit any development within this LRDA. The proposed house is sited
within the only viable LRDA of the lot locate near the northerly boundary. A 200 foot long
driveway serving the house is proposed from Jared Lane. The design of this driveway must meet
the emergency access standards of the Santa Clara County Fire Department (Fire Department).
The Fire Department standards applicable to the proposed driveway are driveway slope shall
not exceed 15%, inside edge radius of driveway shall not be less than 42 feet, and an
emergency turnaround with maximum 5% cross slope for driveway exceeding 150 feet.
Driveway design that does not conform to these requirements will require a submittal of a
variance to be approved by the Fire Department. Because of these requirements, the building
design incorporates a lower level garage that is approximately 20 feet below existing ground to
allow a driveway profile slope of 20% maximum, and an emergency turnaround area with cross
slope of less than 5%. The house site requires cut of approximately 24 feet. A meeting with
Doug Harding, Deputy Fire Marshal, was held on Thursday, February 2, 2017, to discuss
driveway design. Two driveway alternatives were presented at that meeting. Alternative A
included a turnaround area approximately 170 feet from the house and the Alternative B with a
turnaround area approximately 20 feet from the house with driveway slope of 20% maximum.
Doug indicated that the Fire Department would not support Alternative A due to the distance
from the turnaround to the house and would consider Alternative B with a variance for
driveway slope. A second meeting was held on July 10, 2017, with Tracy Staiger, Senior Deputy
Fire Marshal, and Fardean Amadkani, Deputy Fire Marshal, to present the finalized driveway
design and to submit the driveway slope variance. On July 11, 2017, the Fire Department
approved the final driveway design with the slope variance.
The project development package was submitted to the Town of Los Gatos and a hearing was
held on April 11, 2018. The hearing resulted in a request for the redesign of the project’s
driveway to minimize the retaining wall height and grading. A new driveway design (new
driveway) was prepared and submitted to the Town of Los Gatos for review and approval. The
new driveway geometric layout is essentially the same as the previously submitted driveway
design (original driveway). However, its profile is substantially different than original driveway.
The steeper slope, 15% or greater, for the new driveway begins at the edge of pavement of
Jared Lane instead of approximately 14 feet inside the property as originally designed. This
resulted in a driveway that requires less grading, lower retaining wall height and lower profile
grade. Below is a comparison table of the original and revised driveways design prepared by LC
Engineering (LCE); and previously approved driveway design (approved driveway) prepared by
TS Civil Engineering (TS):
C-1
Original Driveway New Driveway Approved Driveway
(LCE) (LCE) (TS)
Driveway width 16 ft 16 ft 12 ft
Maximum driveway slope 19.53% 15% 15%
Height of excavation at garage 15 ft 15 ft 13’+ ft*
Height of excavation (cut) 3 ft 4 ft 1 ft
along driveway
Height of embankment (fill) 16 ft 13 ft 13.5 ft
Maximum retaining wall height 14 ft 8.25 ft 5 ft
Excavation (cut) volume 110 cy 397 cy 140 cy
Embankment (fill) volume 1128 cy 852 cy 774 cy
*Existing ground elevation 543+ ft and garage slab finish floor elevation 530 ft
The new driveway meets the Fire Department standards and requires earthwork excavation of
15 feet maximum and embankment of 13 feet maximum. These values exceed the Standard
and Guidelines of 4 feet cut and 3 feet fill.
To minimize grading and tree removal due to earthwork, tiered retaining walls of up to 8.25
feet high and 212 feet long are proposed along the edges of the driveway. To minimize the
walls potential visual impact, colored and fractured wall finish, such as Allan Block, are
proposed for the wall exposed surface. Heavy landscaping is also proposed along the wall to
further reduce the potential visual impact.
The grading for the new building will require 2891 cy of excavation and 352 cy of embankment.
The previously approved plans prepared by TS Civil Engineering shown grading quantities of
793 cy of excavation.
C-2
(outside LRDA)
Todd Kalbfeld Landscape Design & Construction Management
2345 Tulip Road, San Jose, CA 95128
(408) 605-9973 8/21/2018
Friday May 4th, I continued tree survey with owner, tagging most remaining trees.
We were again able to walk entire site assessing views from all adjacent properties
while recording trees and estimating existing oak heights.
From Existing plan and added trees from site visit, tree assessment is numbered as
follows:
268 total protected trees
12 Total un-protect trees
PART II
One of the potential options to mitigate tree removal and privacy enhanced is to implement the
actual hands-on technique during the construction as expalined below.
Most trees are preserved and protected in accordance with HDS/G as delineated on L-1A & L-1B.
The owner & I both really believe that quite number of trees even are tagged for removal because
of their vicinities to the proposed construction areas close to driveway & building should their fate be
doomed depending on the mitigation takes place during grading with an above-standards site
supervision during construction. This is due to the fact of our observation made gives the owner,
who he's an avid and diligent builder, a far more great chance for him to alleivate the number of trees
to be removed with which there are almost 50% of them could be salvaged.
The locaiton of those potentially preserved trees with red numbered tags can be easily spotted on the
scaled model. A typical sample tree, # 66, though requiring cut due to the build of multi-level side-
yard decks to the house and our owner-builder claims that his confidence & experience let him
having a notion of great chance to preserve it as a imminent shade cover for the sake of leisure
enjoyment after decking erected. Mitigation as described above is one of goals to preserve a natural
environment as possibly as it can be and the house of owner would appreciate the adopted
preservaton techniqes of employing hand-digging around these senstive areas eventually he would
definitely enjoy himself with the preserved environment of an open, wooded, rural character many
many years to come.
PART I
T-1
Neighbor Visit record
258 Jared Ln. Allan Rudolph
5/22/2016 Informed the project planned
7/30/2016 Discussed the tree issues on the property between my land and Allan's
9/4/2016 Obtained the agreement letter for tree trim permission
12/22/2016 Asked to use Allan's easement to proceed my driveway. He kindly rejected.
3/12/2017 Asked to use Allan's easement to proceed my driveway
or buy' land adjacent to his and he kindly rejected again.
4/22/2018 Discussed issues after 4/11 town meeting
268 Jared Ln. Stephen Milligan
9/18/2016 Informed the project planned
253 Vista Del Monte, Mike McDonough
9/18/2016 Informed the project planned
4/22/2018 Visited but missed
5/6/2018 Visited but missed
5/7/2018 Discussed issues after 4/11 meeting.
No major concerns. Love to see the project implemented.
249 Vista Del Monte
9/18/2016 Visited but missed
4/22/2018 Visited but missed
5/6/2018 Visited but missed
5/7/2018 Visited but missed
245 Vista Del Monte
9/18/2016 Visited but missed
4/22/2018 Visited but missed
5/6/2018 Visited but missed
5/7/2018 Visited but missed
254 Vista Del Monte, Mary Martin
4/22/2018 Discussed the project and issues after 4/11 town meeting. No major concerns.
Director of Uplift Family Service, AJ Anderson
4/13/2018 Discussed issues after 4/11 town meeting.
Quite a learning experience on the history of the site.
5/8/2018 Discussed more about trees. Reached an oral agreement that fence or trees will be
installed/planted to screen their swimming pool.
224 Vista Del Mar, Ralph (Ken) Houp
4/11/2018 discussed right after meeting. No any major concerns.
4/22/2018 Visited but missed
5/6/2018 Visited but missed
5/7/2018 Visited but missed
N-1
N-2
O-1
Other Considerations
An unordinary site constraint
Although it’s more than one & one-half acres hillside lot, unfortunately, the amount of
contiguous buildable area is truly limited due the facts to almost 36% slope throughout the
site and a riparian corridor lies through the lower terrain of the site. A LRDA, 30% slope, of
about 6000 sf sought, In which it conforms to Town’s HDSG, unfortunately, 20’ setback leaves
an allowable area for the house site, which is a circular-shaped merely 3300 sf.
A comparable house size in the neighborhood
2800 square feet is a median-sized house amid those built in the neighborhood, particularly in
HR-1 zone.
Architectural Design
It’s well accepted by peer architect, Cannon Design Group, whose comments are that house
though appears large, however, well arranged stepped back facades, small cantilevers and
materials change breaks up some of taller walls on the South side (facing Jared).
Motivation
Sam Pan the current owner found from Town staff that 248 Jared had been officially approved
by Town Planning Commission in 2011, but site permit expired and required filing new
application. The approval of site development really inspired Sam to build his estate & live in
the beautiful town of Los Gatos; therefore, he invested a larger sum of money without
hesitation.
Neighbor’s cooperation
Subsequent to the land deal the owner met neighbor behind his lot and requested an in-and-
out private driveway off upper part of Jared Lane that was a recorded ingress/egress
easement for the only house located at the end of Jared, where a 4600 square feet house built
not long ago. The neighbor declined his request; otherwise, a shorter easier driveway would
be designed.
Neighbors attended 4/11/2018 meeting have had lengthy discussions afterwards with Sam,
who he acknowledged that majority of those neighbors would have no opposition to the
house design. Owner at 253 Vista Del Monte echoes the proposed; the Director of Uplift
Family Service requests higher wood fence and row of trees planted between two properties
so more privacy for children can be achieved; owner at 258 Jared shows concern during the
construction as to locations of trucks loading, unloading and parking spaces allocated to
workers. It appears their concerns or issues more focus on construction activities than design
itself and matters of those the owner will cooperate closely with neighbors as time comes.
Enhanced visual aid
The site & building model delivers a very clear vision of the proposed in terms of the given site
topographic, the house location in the LRDA area where it’s the only area can be developed in
this quasi-hillside property, the slope of driveway & height of retaining wall relatively
proportional to the site & the house it’s a mandate feature making house alive yet meet
O-2
minimum standards as required in the HDS&G, the massing of the house indeed shows it’s not
dominating , the understanding of the privacy amid the adjacent neighbors.
Objective of Planning Commission
The Planning Commission does have authority to grant exceptions to the standards within the
goal of the HDS&G when appropriate and no additional findings would be required.
Upon completion of in-depth studies contained in pages aforementioned, obviously, the 2018
design scheme as whole is superior to the commission-approved standards retained in the
2011 design.
In a summary, the most important is that the owner has been a much diversified builder in the
residential construction business for the past at least 20 years. He will be serving owner-
builder to hands on his dreamed house construction as the time becomes permissible and he
is willing to adhere to conditions that delegated from the Commissioners to finish a nearly
insurmountable task.
Pending completion 8/15/2018
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EXHIBIT 17
PARCEL 1
662-PM-50
GARAGE
LOWER DECK
HI-LEVEL FF=550.50
MID-LEVEL FF=539.50
WLK
DWY
UPPER
DECK
PORCH
PARCEL 1
662-PM-50
SECTION A-A
DWY
GARAGE
FF = 539.5
FF = 550.5
JARED LANE
HI-LEVEL
FF = 550.5
HI-LEVEL
MID-LEVEL
FF = 539.5
MID-LEVEL
LOWER
DECK
FF = 550.5
FF = 539.5
SECTION B-B
HI-LEVEL
MID-LEVEL
PARCEL 1
662-PM-50
PARCEL 1
662-PM-50
30'
Z
O
N
E
1
30
'
-
7
0
'
Z
O
N
E
2
70
'
-
2
0
0
'
Z
O
N
E
3
5
15
12.26